During the second week since the Financial Accounting Standards Board released its Exposure Draft on amendments to FAS 140, the chatter has shifted from ABCP/CDOs to the impact the new rules may have on the broader term market - namely credit card master trust structures, dealer floorplan structures and other MTs with revolving components that had previously enjoyed QSPE and, thus, off-balance sheet status.

A primary area needing clarification in the new draft - and one of the key concerns for the market - involves the definition of "reissuing" beneficial interests, and whether or not subsequent series from a master trust (set up as a QSPE) will be considered reissuance.

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